Skip to main content

Full text of "Uranium Mine Ventilation Costs"

See other formats


M  ■ 


TN  295 


No.  8855 


Set  2 


■  m 


JIB 


H I  ■  I 


■ 


m 

'l;. 


■ 


I 


^^M   ■  H 


G*  V     -..I*      A 


•  •  *  o        <> 


A 


^  °* 


^d* 


A  ^      • 


a    .     ^  •-•;. -o-       V;f";'4^     "^-^^'^     "V"---*/4"    "<."'*^^>^  ViS 


"^ 


*b^ 


vO-A 


:..**    ••  Jfe'-.  \/  .-^-.    V*1 


>v 


.  <\  C  ^  m  AW 


4       **     %       ', 


i:  %/  :&-.  \/  sMk*.  xs  --mi--  \/  y/m-.  %s  ••) 


*        &        &t       »1< 


. » *     A 


<>    *'TT 


•      <^     c^ 


^°^ 


<^   *. 


**<? 


*      ay    "^      • 


'oK 


«p^ 


cr   * 


av-V     j^^^°     ^SV 

A  ^>     ♦'TVT*     .&*  ^> 


A 


A  .0*0.  <f> 


Av       .  0  •  o 


<* 


**.  "••To*   .J- 


••-•-%     ./.-i^i-X   .c0*..^ILt.oo     ./.-^-X   . o°  .-^sii.  °-     ./ 


r-^0% 


j>-^ 
^     ** 


,*v 


:v"^v     v-^'V'    V^-'V     v; 


o  *  »  ,  i  •  " 

« v  ^. 


V^->'...>. 


IC!  8855 


Bureau  of  Mines  Information  Circular/1981 


Uranium  Mine  Ventilation  Costs 


By  Robert  C.  Bates 


UNITED  STATES  DEPARTMENT  OF  THE  INTERIOR 


Information  Circular  8855 

Vl 


Uranium  Mine  Ventilation  Costs 


By  Robert  C.  Bates 


UNITED  STATES  DEPARTMENT  OF  THE  INTERIOR 
James  G.  Watt,  Secretary 

BUREAU  OF  MINES 
Robert  C.  Horton,  Director 


«& 


& 


4^  ^* 


As  the  Nation's  principal  conservation  agency,  the  Department  of  the  Interior 
has  responsibility  for  most  of  our  nationally  owned  public  lands  and  natural 
resources.  This  includes  fostering  the  wisest  use  of  our  land  and  water  re- 
sources, protecting  our  fish  and  wildlife,  preserving  the  environmental  and 
cultural  values  of  our  national  parks  and  historical  places,  and  providing  for 
the  enjoyment  of  life  through  outdoor  recreation.  The  Department  assesses 
our  energy  and  mineral  resources  and  works  to  assure  that  their  development  is 
in  the  best  interests  of  all  our  people.  The  Department  also  has  a  major  re- 
sponsibility for  American  Indian  reservation  communities  and  for  people  who 
live  in  Island  Territories  under  U.S.  administration. 


This  publication  has  been  cataloged  as  follows: 


Bates,  Robert  C 

Uranium  mine  ventilation  costs. 

(Information  circular  ;  8855) 

Bibliography:  p.  18. 

Supt.  of  Docs,  no.:  I  28.27:8855. 

1.  Uranium  mines  and  mining— Safety  measures.  2.  Mine  ventila* 
tion— Costs.  I.  Title.  II.  Series:  Information  circular  (United  States. 
Bureau  of  Mines)  ;  8855. 


TN295.U4         622s  [338.2'3] 


81-607862    AACR2 


For  sale  by  the  Superintendent  of  Documents,  U.S.  Government  Printing  Office 

Washington,  D.C.  20402 


CONTENTS 


Page 


Abstract 1 

Introduction 1 

Background 2 

FRC  staff  report 2 

RMC  report 4 

ADL  study 7 

Analysis 9 

Applications 12 

Cost  of  other  control  measures 16 

Conclusions 17 

References 18 

ILLUSTRATIONS 

1.  Cost  per  ton  for  ventilating  uranium  mines 10 

2.  Costs  for  ventilating  uranium  mines  versus  average  annual  exposure 

with  regression  line 12 

3.  Projected  radiation  control  cost  for  different  Consumer  Price 

Indices  and  average  annual  exposures 14 

4.  Project  radon-daughter  control  costs  versus  limiting  miner  exposure 

WLM  for  several  Consumer  Price  Index  values 15 

TABLES 

1.  Ventilation  cost  estimates,  11-mine  study,  1965 3 

2.  Ventilation  cost  estimates,  3-mine  study 3 

3 .  Modified  WL-control  cost  for  three  smaller  mines 5 

4.  Radon-daughter  control  costs  for  five  large  uranium  mines 6 

5.  Costs  and  radiation  levels  for  various  degrees  of  control 8 

6.  Federal  Radiation  Council  Report  8  uranium  mine  ventilation  cost 

data  converted  to  1967  dollars  per  ton 9 

7.  Uranium  mine  ventilation  cost  data  from  Spencer  converted  to 

1967  dollars  per  ton 10 

8.  Average  ventilation  costs  and  working  place  radon-daughter 

concentrations 11 

9.  Consumer  Price  Index  (1967  =  100) 13 

10.  Cost  per  ton  at  CPI  =  250  (1980$)  for  several  average  WLM  exposures  13 

11.  Cost  per  ton  at  CPI  =  250  for  several  limiting  miner  exposures  WLM.  15 

12.  Cost  for  radon  control,  from  Kown 16 


URANIUM  MINE   VENTILATION   COSTS 
by 

Robert  C.  Bates1 


ABSTRACT 

This  Bureau  of  Mines  report  converts  published  data  on  the  cost  of  venti- 
lating uranium  mines  to  a  common  price  base  and  analyzes  these  data  to  deter- 
mine the  cost  per  ton  of  uranium  ore  at  various  levels  of  radiation  exposure 
control.   There  appears  to  be  an  exponential  increase  of  cost  as  the  radiation 
level  is  lowered.   The  1967  base  costs  are  extrapolated  to  present  dollars, 
and  some  cost  comparisons  are  given  for  other  radiation  control  measures. 

INTRODUCTION 

Since  about  1950,  the  Bureau  of  Mines  has  been  concerned  about  radon- 
daughter  concentrations  in  uranium  mines.   For  a  considerable  time,  this 
interest  was  primarily  oriented  toward  control  by  ventilation.   Ventilation  is 
the  most  common  airborne-radiation  control  measure  used  in  uranium  mines. 
However,  as  the  mines  become  deeper  and  larger,  ventilation  costs  increase 
tremendously  and  all  available  radiation  control  methods  must  be  used  to  help 
reduce  the  radiation  hazards. 

In  1973,  the  Bureau  began  investigating  other  methods  to  control 
airborne-radiation  levels  and  reduce  ventilation  requirements.   Laboratory, 
field,  and  theoretical  evaluations  were  made  of  sealants,  bulkheading,  radon 
removal,  overpressurization,  and  radon-daughter  removal.   Costs  were  deter- 
mined for  several  control  techniques.   For  example,  the  cost  for  removing 
radon  from  the  air  was  found  to  be  prohibitive  (2).2 

In  1973,  a  Bureau  study  was  performed  of  data  from  three  reports  (_1,  b_> 
10)  to  estimate  the  cost  of  mine  ventilation  in  terms  that  could  be  related 
to  control  measure  costs.   These  were  the  only  reports  that  had  seriously 
discussed  the  cost  of  ventilating  uranium  mines.   Since  then,  a  study  of 
procedures  for  setting  standards  for  radon-daughters  has  become  available  (5). 
It  evaluated  the  information  in  the  three  previous  reports  and,  among  other 

Supervisory  mining  engineer,  Spokane  Research  Center,  Bureau  of  Mines, 

Spokane,  Wash. 
2Underlned  numbers  in  parentheses  refer  to  items  in  the  list  of  references  at 

the  end  of  this  report. 


things,  developed  an  exponential  equation  for  ventilation  costs.   The  informa- 
tion given  in  the  literature  is  not  directly  applicable  for  cost  comparisons. 
Therefore,  the  following  text  describes  these  three  studies,  describes  the 
analysis  methods,  compares  the  results  with  those  of  Cross  (5),  projects  the 
costs  for  various  radon-daughter  exposure  limits,  and  comments  on  some  costs 
of  radon  and  radon-daughter  control  measures. 

BACKGROUND 

The  three  reports  studied  (1_,  6^,  10)  had  been  sponsored  by  the  Federal 
Radiation  Council.   The  analysis  base  and  philosophy  for  each  were  somewhat 
different,  thus  making  direct  comparisons  difficult.   For  example,  three  dif- 
ferent parameters  were  used  as  the  exposure  bases  for  the  three  reports — aver- 
age working  level,3  mine  index,  and  "last  man"  working  level.   The  mine 
average  WL  might  or  might  not  be  representative  of  the  miners'  exposure, 
because  extremely  low  values  in  haulageways  or  intake  shafts  can  be  averaged 
with  the  supposedly  higher  ones  in  the  stopes.   A  more  representative  value 
for  the  person's  exposure  is  the  mine  index,  which  uses  the  weighting  of  occu- 
pancy time  and  the  number  of  persons  involved  to  calculate  the  average.   The 
third  concept,  the  "last  man"  working  level  exposure,  represents  the  highest 
annual  exposure  recorded  for  any  underground  personnel.   The  ventilation  costs 
are  also  given  in  two  different  ways,  dollars  per  ton  of  ore  produced  and 
dollars  per  pound  of  u^Os*   The  information  available  in  these  reports  is 
described  briefly  in  the  following  paragraphs. 

FRC  Staff  Report 

A  Federal  Council  (FRC)  staff  report  (6^)  summarizes  quite  a  bit  of  the 
information  available  on  the  radiation  problem  in  uranium  mines.   Although 
various  control  methods  were  available,  ventilation  was  the  most  important. 
Since  published  information  on  ventilation  costs  was  not  available,  the  FRC 
staff  requested  a  number  of  uranium  mining  companies  to  carry  out  ventilation 
cost  studies.   As  they  state  (6^,  p.  34),  "These  estimates  are  intended  to 
illustrate  the  general  magnitude  of  cost  in  a  few  selected  mines  and  are  not 
applicable  to  the  industry  as  a  whole."  The  studies  were  divided  into  two 
groups.   One  covered  11  larger  underground  mines  that  accounted  for  more 
than  20  pet  of  the  U.S.  uranium  ore  production,  and  the  other  group  covered 
3  mines  that  produced  about  2  pet  of  the  national  total. 

An  exposure  index  was  developed  for  the  first  group  using  time-weighted 
average  exposures  that  were  weighted  by  the  number  of  persons  involved  in  each 
of  the  worker  categories.   Estimates  were  made  of  the  radon-daughter  concen- 
trations for  minimal  ventilation,  and  costs  were  tabulated  for  various  levels 
of  radiation  control.   Ventilation  and  operating  costs  were  projected  over  a 
10-year  period.   Table  1  in  their  report  is  repeated  here  as  table  1. 


3 "Working  level"  (WL)  means  any  combination  of  the  short-lived  radon  daughters 
in  1  liter  of  air  that  will  result  in  the  ultimate  emission  of  1.3  x  105 
million  electron  volts  (MeV)  of  alpha  energy. 


TABLE  1.  -  Ventilation  cost  estimates,  11-mine  study,  1965  (6) 


(Million  dollars) 


Investment 

Operating  cost 

Total  cost 

Estimated  mine 

cost 

(10-year  est.) 

( 10-years) 

index  WL 

Past  experience 

3.9 

7.9 

11.8 

*2 

Estimated  ventilation 

cost  without  radon 

2.0 

2.8 

4.8 

210 

Additional  cost  for 

radon  control  from 

1.9 

5.1 

7.0 

Estimated  additional 

cost  to  reduce  from 

1.5 

6.0 

7.5 

1 

Total  cost  to  control 

at  1  WL — 10  years.. 

19.3 

^Composite  mine  index  for  1965. 
2Estimate  of  what  the  average  WL  concentration  would  be  with  normal 
ventilation  practices. 

The  second  group  of  three  mines  was  considerably  different  from  the 
11  mines  in  geology,  depth,  extent  of  working,  productive  capacity,  arrange- 
ment of  passageways,  numbers  of  openings,  and  so  on.   The  reporting  of  the 
information  was  also  different.   Ventilation  and  operating  costs  were  pro- 
jected over  a  6-year  period  instead  of  a  10-year  period,  and  the  working-level 
values  were  reported  as  1-year  averages,  rather  than  the  mine  index  value  used 
for  the  11-mine  study.   Table  2  of  the  FRC  staff  report  (6)   is  given  in  its 
entirety  as  table  2  in  this  report. 

TABLE  2.  -  Ventilation  cost  estimates,  3-mine  study  (6) 


(Thousand  dollars) 


Investment 
cost 

Oper.  cost 
(6-year  est.) 

Total  cost 
(6-years) 

Average 
concentration, 
WL 

Past  experience: 

361 

321 

75 

120 
85 

50 

481 
406 
125 

1IA 

ll.5 

11.5 

757 

63 

66 

6 

255 

21 

18 

4 

1,012 

84 
84 
10 

Estimated  for  case  of 
minimum  ventilation: 

25-20 

135 

43 

178 

Average  WL  concentrations  in  1965. 
2Estimate  of  what  the  average  WL  concentrations  would  be  with  normal 
ventilation  practices. 


RMC  Report 

Spencer  (10)  of  the  Resource  Management  Corp.  (RMC)  examined  a  number  of 
items,  including  costs,  associated  with  the  control  of  radon  daughters  in  ura- 
nium mines.   Although  literature  was  collected,  much  of  the  information  came 
from  personal  discussions  with  knowledgeable  government  and  industry  people. 
From  these  discussions,  Spencer  decided  to  limit  their  studies  to  the  Colorado 
Plateau  region  (Uravan  mineral  belt  and  Ambrosia  Lake).   Their  evaluations 
also  led  RMC  to  the  conclusion  that  only  two  approaches,  historical  and  mod- 
eling, appeared  usable  for  cost  estimating.   Historical  data  could  provide  a 
relationship  between  cost  and  working  levels  from  which  they  could  extrapolate 
to  the  average  mine  with  a  0.3-WL  concentration.   Although  this  technique  has 
a  number  of  inadequacies  stemming  from  the  wide  range  in  the  characteristics 
of  the  mining  operations  supplying  the  data,  it  was  possible  for  RMC  to 
arrive  at  some  figures  in  a  very  short  time.   The  modeling  approach,  because 
of  the  complexity  of  the  mining  process  itself,  was  too  complex  for  the  short 
time  period  of  the  study.   Therefore,  data  were  requested  and  received  from 
eight  operating  mines  (three  small  and  five  large)  for  3  years  of  production, 
1966,  1967,  and  1968. 

The  three  small  mines  had  relatively  small  output  tonnages  but  fairly 
large  underground  areas.   Costs  included  supplies,  labor,  power,  air  courses, 
and  capital  investments.   Capital  and  ventilation  costs  for  drifts  and  raises 
were  amortized  over  a  5-year  period.   The  capital  expenditures  were  reportedly 
amortized  over  a  10-year  period.   A  summary  of  their  data  is  given  in  table  3. 
The  radon-daughter  concentrations  are  given  as  average  working  levels. 


TABLE  3.  -  Modified  WL-control  cost  for  three  smaller  mines  (10) 


Mine  and  year 

Ore  output, 
10 3  tons 

Average  con- 
centration, WL 

Cost  per  ton 
of  ore1 

Modified  cost 

per  ton  of 

ore2 

Mine  A: 3 

1966 

12 
9.4 
7.7 

44.0 
3.0 
2.2 

34.1 
36.2 
29.3 

16.7 
16.2 
13.1 

2.2 
2.1 

.7 

3.1 

2.1 

.6 

1.3 

1.3 

.5 

1.66 

1.50 

.55 

$0.33 

1.10 

.51 

.47 

1.38 

.90 

.21 

.47 

2.19 

.26 

.65 

1.79 

$0.28 

1967 

.64 

1968 

.57 

Mine  B:3 

1966 

.43 

1967 

1.08 

1968 

.89 

Mine  C : 3 

1966 

.20 

1967 

.44 

1968 

1.47 

Average: 5 

1966 

.24 

1967 

.52 

1.26 

Capital  expenditure  written  off  over  10  years;  some  totals  in  RMC  report  (10) 

appeared  to  be  wrong,  so  recalculated  values  were  used. 
2Cost  of  air  courses  amortized  over  5  years. 
3Data  are  for  1st  half  of  year. 

4 1966  output  of  mine  B  was  not  available;  assumed  by  extrapolation, 
individual  mine  data  averaged  by  tonnage  ore  output. 


The  owners  of  the  five  larger  mines  reported  total  capital  assets  in  the 
original  data,  but  Spencer  used  only  the  incremental  capital  expenditures  for 
the  period  of  interest.   Therefore,  certain  capital  costs  did  not  contribute 
to  the  1966-68  working  level  reductions.   However,  the  improvements  in  concen- 
tration are  shown  as  functions  of  new  capital  investments  and  increased  oper- 
ating and  maintenance  costs.   The  working  level  averages  given  in  their  tables 
are  not  based  on  personal  exposures  but  are  simple  arithmetic  averages  of  per- 
iodic readings  taken  by  the  mine  operator  in  the  occupied  areas  of  the  mine. 
In  one  sense,  since  most  of  the  underground  workers  are  in  areas  of  higher 
radon  concentration,  the  average  exposure  might  be  higher  than  the  data  indi- 
cate.  Further  analysis  (based  on  some  additional  information  supplied  by  the 
owners)  indicated  that,  for  the  period  studied,  average  exposures  and  aver- 
age working  levels  were  equal.   A  summary  of  the  five-mine  data  is  given  in 
table  4. 


TABLE  4.  -  Radon-daughter  control  costs  for  five  large  uranium  mines  (10) 


Mine  and  year 


Mine  average 


WL's 


1 


Ore  output, 1 

Total  costs 

103  tons 

per  ton2 

132 

$0.76 

115 

.86 

79 

.92 

237 

.57 

278 

.57 

154 

.71 

119 

.67 

184 

.87 

104 

.84 

212 

.55 

276 

.66 

150 

.88 

84 

.64 

154 

.51 

78 

.74 

157 

.62 

201 

.67 

113 

.81 

Mine  D: 


1967 

1968 3 

Mine  E: 

1966 

1967 

1968 3 

Mine  F: 

1966 

1967 

1968 3 

Mine  G: 

1966 

1967 

1968 3 

Mine  H: 

1966 

1967 

19683 

Average: ^ 

1966 

1967 

19683 

2.0 
.8 
.4 


2.2 

1.1 

.5 


1.6 

1.4 

.5 


2.3 

1.3 

.7 


1.5 

1.1 

.6 


2.03 

1.18 

.55 


Original  WL  data,  given  for  each  half  of  each  year,  were  weighted  by  ore 

output  for  each  6-month  period  to  arrive  at  these  yearly  averages. 
2Includes  new  capital  costs  at  10-yr  writeoff. 
3First  half  of  1968  only. 
^Some  values  recalculated  from  published  table  (10,  table  3). 

The  mathematical  analysis,  cost  versus  working  level,  of  the  three-mine 
data  yielded  a  linear  equation,  and  that  of  the  five-mine  data  an  exponential 
equation.   Their  calculations  indicate  that  to  keep  the  highest  exposure  under 
0.3  WL,  the  mine  average  must  be  0.15  WL.   Extrapolating  to  this  low  level, 
they  estimated  a  cost  of  approximately  $1.05  per  ton.   Thompkins  (11)  took 
exception  to  this  calculation  and  drew  another  curve  through  their  data,  indi- 
cating that  it  would  be  impossible  to  achieve  less  than  a  0.5-WL  average, 
regardless  of  how  much  money  was  spent  on  ventilation. 


ADL  Study 

The  study  by  Arthur  D.  Little,  Inc.  (ADL)  for  the  Federal  Radiation  Coun- 
cil CO  is  the  most  thorough  evaluation  of  costs  relative  to  radon-daughter 
control  that  is  available.   ADL  personnel  selected  a  sample  of  26  underground 
uranium  mines  that  would  represent  the  underground  uranium  mining  industry. 
In  addition,  they  covered  the  more  important  producing  regions,  including 
large  and  small  mines,  old  and  new  mines,  and  mines  with  high  and  low  emana- 
tion rates.   For  early  1970,  at  the  time  of  radon-daughter  sampling,  the 
26  mines  represented  29  pet  of  the  mines,  81  pet  of  the  production,  and  88  pet 
of  the  underground  employees  in  the  United  States. 

The  information  supplied  by  each  mine  operator  included  working  levels 
and  costs.   Some  operators  furnished  data  on  percentages  of  underground  miners 
receiving  exposures  in  various  working-level-month  (WLM)1*  ranges.   They  also 
supplied  detailed  mine  maps  showing  the  location  of  ventilation  holes,  fans, 
secondary  air  bags,  measured  working  levels,  and  airflow  at  various  points  in 
each  mine.   The  measurements  recorded  were  taken  in  March  1970.  From  all  of 
the  working-level  data,  ADL  personnel  were  able  to  calculate  three  figures  to 
characterize  the  situation  at  each  mine: 

1.  Mine  working-place  average  working  level,  which  is  the  average  of  all 
working  level  readings  reported  in  working  places  and  access  ways  on  the  mea- 
surement day. 

2.  Maximum  working  level,  which  is  the  highest  value  reported  in  any 
working  place  on  the  evaluation  date. 

3.  The  "last  man"  working-level-month,  which  is  the  highest  1969  expo- 
sure recorded  for  an  individual.   The  costs  for  ventilation  and  radiation  con- 
trol included  fan  power,  maintenance,  heating,  and  labor  for  ventilation  and 
sampling,  as  well  as  capital  costs  for  ventilation  holes  and  other  ventilation 
equipment. 

After  gathering  the  baseline  information,  ADL  had  a  team  of  mining, 
ventilation,  and  radiation  control  experts  study  each  mine  to  establish  the 
changes  that  would  be  necessary  to  assure  that  a  reading  of  0.3  or  0.6  WL 
would  not  be  exceeded  in  any  working  or  travel  area.   These  would  then  equate 
4  or  8  "last  man"  WLM  exposures.   A  design  was  developed  for  each  mine  to 
assure  satisfying  the  4  and  8  WLM  per  year  standards.   The  incremental  costs 
were  calculated  using  standard  unit  costs.   New  investments  such  as  additional 
drill  holes,  fans,  bulkheads,  and  air  heaters  were  included.   The  additional 
operating  costs  for  power,  labor,  fuel,  and  supplies  were  also  considered. 
Amortization  for  new  capital  items  was  done  against  1  year's  ore  production 
from  the  mine.   This  procedure  does  result  in  higher  costs  than  would  be 
expected  if  the  amortization  was  done  more  on  a  basis  of  the  total  ore 
reserves,  if  these  had  been  known.   Data  extracted  from  the  ADL  report  are 
given  in  table  5. 

^Inhalation  of  air  containing  a  radon-daughter  concentration  of  1  WL  for 
173  hr  results  in  an  exposure  of  1  WLM. 


-I 


co 
9) 

CD 

u 

60 

0) 
13 

CO 

3 

o 

•H 
J-i 
cd 

> 

u 
o 

<4-l 


c 
o 
•w 
■u 
cd 
•H 

-o 

cd 
TJ 

cd 

CO 
4-) 

co 
o 
o 


H 


<u  a 

Vj  O 
O   vH 

4-> 
4-1  cfl 
O   «H 

Tj 
C  cd 
O    U 


U 

CO     S 


CO         •> 

cd     cu 

3 
co 
o 
o. 

X 
cu 


o> 

ON 


60     <D 


c 

60 

•H 

c« 

-*i 

u 

J-l 

<u 

O 

> 

5 

cd 

cu 

c 

£ 

CO  o 

en  co       ^iDconvooinHnocMAHO*       ovoo<toiOOco 

OinHOWNHIf>COONNO\*<fi-ifl\^fOOin(fHOCO\OCOin(N 


CM  —I 


CMi— l-*«*«tfCOvOOI      ^H 


^H  CM  ,— I 


r»»  cm 

O  CO  ON  o 


CM 


N  S\ON 
00  O  CO  00 


00    UO 

coo>* 


o  o 


-tf  CM 


CN 


o  o 


—i  o 
vooooo  r>-  m  co  ,— i,-(o 
coi-H^HOc^ococoo<-oom 


\o  as 
r^cMCMmoor^omcNcococM^H«vj^H^Hsovoo>omooooor>.co 

N«*N-*cninff>c^<jcM-*\ooo-*SNinvooNvoo\oocooocoooooo 


.— I    i— I    i— I   .— I    .— I    CM   i— I 


HHHHHHNcoroncocOHH 


m 

OOOOOOOOOOOOOOOOOOOOOOOOOOCO 

NifHONn^OOHO^ONsOONNOavOOClvBOOstvOvO*    &, 

< 

NHOHCO»NO\0\vOHNSN*\OONCOCO-*OmrONiOCOCOZ 

i— I    i— I  i— I  i— I  i—l  i— I  t-H^.— I 


r-~  on 
oor-^cMoo^HOOcoo\oovoOOOcovooocMcomr-.r^t^cocMOoor^ 

<frN<tHHinN\OiflirivD>JsvOH>a,roNrOHkO(Mcn<>*in<fco 


•  -O 

cu  cu 

60  4J 

cd  & 

U  60 

CU  -H 

>  a> 

<ti  S 


HNcn^irnoscowo 


irnDsco»OHNro>jirnD 

hhhhhNNNNNNN 


00 

*o 
cd 
o 

co 
cu 

iH 
X> 

cd 


o\ 
co 


cd 

•  4J 

cu 

-t  •> 

cd 

o  cu 

H  O 

H  C 

a  cu 

a  n 

cd  <u 


oo 

cu  •* 
o 

j-  cu 

CD  iH 

u  x> 

cu  cd 

<4-l  4-1 

cu 

j-i  « 

e 

o  cu 

n  o 

14-1  C 

cu 

cu  cu 


4J    cu    cd 


s 

o 

a.  u 


CM 

-* 

CU 

rH 

• 

,o 

4-> 

CO 

X 

■W 

CU 

"            4J 

*. 

i—l 

CU 

<u 

CU 

co 

o 

• 

c 

H)      •» 

0) 

4J  T3 

n 

cd   cu 

QJ 

S    4J 

M-l 

•h  cd 

CU 

X    rH 

!-l 

0    3 

r4      O 

B 

&H 

O 

a  cd 

u 

<3  u 

En 

rr    ir> 

lO 

ANALYSIS 

Since  these  studies  spanned  a  5-year  period,  the  cost  data  should  be  put 

on  a  common  base  before  analysis.   The  Consumer  Price  Index  (CPI),  also  known 

as  Cost  of  Living  Index,  was  used  to  change  all  costs  to  1967  dollars  (1967$); 
hence  CPI  =  100  in  1967. 

The  Federal  Radiation  Council  data  (6)  first  required  a  calculation  of 
the  estimated  tonnage  for  the  mines  over  a  10-year  period.   In  1965,  the 
11  mines  (table  1)  produced  over  20  pet  of  the  total  U.S.  production,5  which, 
at  exactly  20  pet,  amounts  to  872,523  tons  of  ore.   Therefore,  the  10-year 
production  is  over  8.73  million  tons.   Table  6  gives  the  ventilation  control 
costs  converted  to  dollars  per  ton.   The  three  small  mines  produced  approxi- 
mately 87,252  tons  of  uranium  ore  in  1965,  or  approximately  0.52  million  tons 
in  the  6-year  analysis  period  (table  6).   The  working  level  month  figures  and 
1967  dollars  per  ton  are  plotted  in  figure  1. 

TABLE  6.  -  Federal  Radiation  Council  Report  8  (6)  uranium  mine  ventilation 

cost  data  converted  to  1967  dollars  per  ton 


Item 

Total  cost, 
millions 

Cost  per  ton 

Mine  index 
or  average  WL 

WLM 

In  1965$ 

In  1967$ 

11-mine  study  (10-yr): 
Minimum  ventilation. 

3-mine  study  (6-yr): 
Minimum  ventilation. 
Control  to  1.5  WL... 

$4.8 
11.8 
19.3 

.18 
1.01 

$0.55 
1.35 
2.21 

.34 
1.93 

$0.58 
1.43 
2.34 

.36 

2.04 

ho 

2 
1 

^-20 
31.5 

120 

24 
12 

2150 
18 

^-Estimate  of  average  WL  with  normal  metal  mine  ventilation  practice. 
2Midrange,  12.5  WL,  used  to  calculate  WLM. 
3Average  concentration. 

It  is  assumed  that  the  costs  supplied  to  Spencer  (10)  by  the  mine  owners 
are  CPI-corrected  for  each  year  during  1966-68.   Table  7  summarizes  the  data 
and  the  conversions  to  1967  dollars  (1967$).   These  data  and  the  production- 
weighted  averages  for  all  eight  mines  are  also  plotted  in  figure  1.   As 
expected,  because  of  the  much  greater  tonnage,  the  weighted  average  is  very 
close  to  the  values  for  the  five  larger  mines.   Cross  (5)  pointed  out  that 
Spencer  ( 10)  neglected  the  succeeding  years'  equipment  amortization  and  return 
on  investment.   This  may  have  resulted  in  a  cost  understatement  of  20  percent; 
the  corrected  data  are  also  plotted  in  figure  1. 


5Total  U.S.  production  in  1965  was  4,362,614  tons  (3). 


10 


TABLE  7.  -  Uranium  mine  ventilation  cost  data  from  Spencer  (10) , 

converted  1967  dollars  per  ton 


Item 

Cost  per  ton 

Cost,    1967  dollars 
per  ton 

Average 
WL 

WLM 

Three  smaller  mines: 

1966 

$0.24 

.52 

1.26 

.62 
.67 
.81 

$0.25 

.52 

1.21 

.64 
.67 
.78 

1.66 

1.50 

.55 

2.03 

1.18 

.55 

20 

1967 

18 

1968 

6.6 

Five   larger  mines: 

1966 

24 

1967 

14 

6.6 

10 
9 
8. 

7. 
6. 

5.  _ 


o 

3 

^* 

K 

(O 

0> 

? 

*" 

H- 

co 

O 

o 

z 
o 

1 
.9 
.8 

t- 

7 

< 

_l 

b 

K 

5 

Z 

HI 

> 

.4 

.3  _ 


.2  _ 


— 

o 

KEY 

1  1-mine    study,  FRC 

— 

V 

3-mine    study,  FRC 

— 

o 

S     larger   mines,  RMC 

a 

X 

3    smaller    mines,  RMC 



D 

Weighted    average   of  RMC  data 

: 

A 

a                o 

V 

+ 

a 

RMC    weighted   average 
corrected  for  20%  cost  error 
by  Cross  (5) 

Average  cost  and  WLM  data,  ADL 

B 
A 

X 

o 

A 

Estimated  weighted  average  of 
ADL  data 

— 

+              A 

8 

+ 

+ 

8 

o 

— 

X 

— 

V 

— 

1             1 

1    1  1  MM 

X 

1 

1 

1     1    1    1  III 

I           I         I       I      I     I     II 

10.  I00. 

AVERAGE  ANNUAL  EXPOSURE,  WLM 


1,000. 


FIGURE  1.  -  Cost  per  ton  for  ventilating  uranium  mines. 


11 


The  ADL  study  (1)  had  as  its  sole  purpose  to  derive  the  total  costs  and 
impacts  of  decreasing  the  allowed  radon-daughter  exposure.   The  data  for  all 
26  mines  are  given  in  table  5.   There  is  considerable  scatter  in  the  informa- 
tion; therefore,  care  was  taken  to  arrive  at  reasonable  averages.   The  authors 
of  the  ADL  report  provided  production-weighted  incremental  costs  to  arrive  at 
8  and  4  WLM  exposures  (table  5),  but  two  key  items  are  missing  from  the  ADL 
survey — "present  weighted  average  cost  per  ton"  and  "present  average  working 
level."   These  are  estimated  in  two  ways,  arithmetic  averages  and  using  the 
observed  differences  in  the  average  value  and  the  ADL  production-weighted 
average  costs.   These  are  given  in  table  8,  and  plotted  in  figure  1. 

TABLE  8.  -  Average  ventilation  costs  and  working  place 
radon-daughter  concentrations 


Cost  per  ton, 
1970$ 

Cost  per  ton, 
1967$ 

Average  WL 

Item 

Using 
table  5 
averages 

Using 
table  5 
weighted 
averages 

Using 
table  5 
averages 

Using 
table  5 
weighted 
averages 

Average  WLM 

Present  conditions 
Last  man  =  8  WLM. . 
Last  man  =  4  WLM. . 

1.88 
2.69 
5.19 

1.03 
1.53 
2.76 

1.66 
2.38 
4.59 

0.91 
1.35 
2.44 

0.487 
!.451 
*.226 

5.8 
5.4 
2.7 

1Ratio  calculated  from  table  5  averages  used  to  calculate  average  WL, 


The  best  values  from  the  three  studies  are  plotted  together  in  figure  2, 
and  a  least-squares  line,  calculated  in  logarithmic  space,  has  been  drawn 
through  the  data.   The  equation  for  this  line  is 


1967$/ton  =  3.134  (WLM)"0- 3715, 


(1) 


with  a  correlation  coefficient,  R  =  -0.75. 


The  95-percent  confidence  limit  on  the  expected  value  of  the  mean  is,  in 
1967$/ton,  approximately  $1.10±$0.07,  and  for  a  particular  value  of  the  mean 
it  is  $1.10±$0.32.   An  equation  was  also  calculated  using  the  average  val- 
ues.  This  equation  has  a  steeper  slope  and  larger  intercept: 


and 


1967$/ton  =  4.616  (WLM)-0' **8 19, 
R  =  -0.77. 


(2) 


In  both  cases,  the  fit  is  significant  at  the  0.01  level  (99-percentile) ,  but 
the  first  equation  is  used  in  the  remainder  of  this  paper  since  it  includes 
the  corrections  that  are  considered  necessary.   The  exponential  model 
developed  by  Cross  (5)  from  the  individual  mine  data  is  given  in  cents  per 
pound  U3O8  (1969  dollars)  versus  average  annual  exposure.   By  converting  their 
equation  to  dollars  per  ton  (assuming  0.22  pet  U3O3  ore  grade)  and  1967 
dollars,  it  becomes 


1967$/ton  =  3.979  (12WL)-0-63. 


(3) 


12 


r   4. 


I 


— 

KEY 

— 

O   1  1-mine   study,  FRC 

— 

V    3-mine   study.  FRC 

— 

+   Weighted  average  of  RMC 

--■^^A 

o 

data   corrected   for   20%   error 
by  Cross  (5) 

A    ADL  data  with  corrected  cost 
and  WLM 

A 

V 

o 

/1967$/ton  =  3.134    (WLM)"03715 

+ 

/                        R  =  -075 

— 

A 

— 

+ 

+ 

— 

^""■"^■^o 



V                        ^-x^^ 

— 

1              1 

Mill 

II 

1 

1 

I  I  1 1  III        I     I    

2  — 


I.  10.  I00. 

AVERAGE  ANNUAL  EXPOSURE. WLM 

FIGURE  2.  -   Costs  for  ventilating  uranium  mines  versus  average  annual  exposure  with  regression  line. 

This  equation  has  a  larger  intercept  and  a  much  steeper  slope  than  the 
equation  developed  from  weighted  average  costs  and  working  levels.   Higher 
cost  estimates  for  control  to  1-  to  2-WLM  annual  exposures  results  when  this 
equation  is  used. 

APPLICATIONS 


1,000. 


Equation  1  can  be  used  with  some  limitation  to  estimate  the  industry 
average  cost  for  ventilating  uranium  mines  at  any  desired  average  working 
level  at  any  consumer  price  index  and  provide  comparisons  with  other  radiation 
control  costs. 


13 


The  inflationary  rise  in  the  Consumer  Price  Index  since  1965  is  shown  in 
table  9.  Since  the  data  used  in  the  analysis  were  converted  to  the  1967  base 
CPI,  it  is  a  simple  matter  to  multiply  the  calculated  cost  per  ton  by  the  new 
CPI  divided  by  100,  as  follows: 


$/ton  =  3.134 


CPI 
100 


(WLM) 


-0.3715 


=  0.03134  CPKWLM)-0'3715. 
An  example  for  CPI  =  250  (1980$)  is  given  in  table  10  and  figure  3. 
TABLE  9.  -  Consumer  Price  Index  (based  on  1967  =  100) 


1965.... 

94.5 

1972 

125.3 

1979 

217.6 

1966.... 

97.2 

1973 

133.1 

1980.... 

246.9 

1967.... 

100.0 

1974.... 

147.7 

1981: 

1968 

104.2 

1975 

161.2 

Jan. . . 

260.7 

1969.... 

109.8 

1976 

170.4 

Feb... 

263.5 

1970 

116.3 

1977 

181.5 

Mar. . . 

265.2 

1971 

121.3 

1978 

195.3 

Apr . . . 

266.8 

TABLE  10.  -  Cost  per  ton  at  CPI  =  250  (1980$) 
for  several  average  WLM  exposures 


Average  WLM 

Cost  per  ton 

At  CPI  =  100 

At  CPI  =  250 

4 

$1.87 

$4.68 

2 

2.42 

6.06 

1 

3.13 

7.84 

.7 

3.58 

8.95 

(4) 


14 


30. 


w" 

i- 
v> 
o 
o 

■_l 

o 

IX 

I- 
z 
o 
o 


:o. 

^^^^      ^**s,n^           i 

10. 

^_     i 

9. 

^^  ^^j^H^ 

^ — J 

8. 

^^>^    ^  ""* 

Sw       i^^*^ 

7. 

^H^^-^ 

6. 

^^ 

^x\r* 

^>«^ 

5. 

4. 

i 

J"*"^ 

^^^ 

NS>^O^^P^^ 

3. 

0.7 

WLM   "  last    man"              t 

r*"*" 

^ 

1    WLM   "  last   man 

/  ***"•- 

^^^o-^O^^T^-^ 

2. 

2    WLM    "  last 

man"-"                   T*""".*^^                   ""^s>>Vn^          "^^^^     "^^^^  ^"""^^^ 

4   WLM   *  last   man 

1  . 
.9 

.8 

.7 

.6 

.5 

.4 

.3 

.2 

.1 

I            I         I       I      I     I    I 

II                    1 

1     1    1   Ml 1   1  1  II 

FIGURE  3. 


I.  10. 

AVERAGE   ANNUAL   EXPOSURE.   WLM 

Projected  radiation  control  cost  for  different  Consumer  Price  Indices  and 
average  annual  exposure. 


100. 


At  this  point,  the  "last  man"  exposure  should  be  introduced.   If  an 
average  working  level  exposure  of  4  WLM  is  maintained,  some  miners  will  be 
overexposed.   Therefore,  we  should  make  the  projections  based  on  limiting  the 
maximum  exposure.   Information  in  the  ADL  report  (1_)  indicated  a  factor  of 
1.478  between  the  average  working-level-month  exposure  and  the  "last  man" 
exposure.   After  incorporating  both  "last  man"  exposure  and  consumer  price 
index,  equation  1  becomes — 


DPT  =  0.03624  CPI  (LME)-0'3715, 

where   DPT  =  dollars  per  ton  corrected  for  CPI, 

and     LME  =  limiting  miner  exposure  (the  highest  annual 

exposure  received  by  an  underground  employee) 


(5) 


15 


Table  11  gives  an  example  of  several  limiting  exposures  at  a  CPI  of  250. 
information,  along  with  several  other  CPI's,  is  shown  in  figure  4. 


This 


TABLE  11.  -  Cost  per  ton  at  CPI  =  250  for  several 
limiting  miner  exposures  WLM 


Limiting  miner 

expos 

ure, 

Average 

WLM 

Cost  per  ton 

WLM 

at  CPI  =  250 

4 

2.71 

$5.41 

2 

1.35 

7.00 

1 

.68 

9.05 

.7 

.47 

10.34 

30. 


20. 


10. 

9. 

8. 

c 
o 

7. 

«■* 

6. 

<A 

5. 

co 

H 

4 

» 

o 

o 

3. 

-1 

o 

a. 

2 

K 

z 

o 

o 

z 

o 

1 

1- 

.9 

< 

.8 

o 

.7 

< 

.6 

cr 

.5 

.4 

.3 


.2 


1.  10. 

LIMITING    MINER    EXPOSURE,    WLM 


100. 


FIGURE  4.  -   Project  radon-daughter  control  costs  versus  limiting  miner  exposure  WLM 
for  several  Consumer  Price  Index  values. 


16 


In  looking  at  these  projected  costs  for  radiation  control  in  uranium 
mines,  it  is  apparent  that  they  are  significant.   The  underground  uranium  ore 
production  in  1979  was  approximately  6  million  tons  (8).   Therefore,  the  esti- 
mated present  cost  is  over  $32  million  per  year  if  the  industry  is  truly  main- 
taining 4  WLM.   If  the  limit  is  reduced  to  2  WLM,  the  estimated  total  cost  is 
$42  million;  for  a  1-WLM  limit,  it  is  $54  million,  and  for  a  0.7-WLM  limit,  it 
is  $62  million.   Clearly,  any  change  in  permitted  exposure  levels  can  have  a 
serious  economic  impact  on  mining  costs.   Also,  as  mines  become  deeper  and 
larger  than  the  mines  in  the  1965-70  base  period,  the  total  cost  for  ventila- 
tion is  going  to  increase  significantly,  unless  other  control  measures,  are 
used  to  cut  the  ventilation  requirements. 

COST  OF  OTHER  CONTROL  MEASURES 

Even  with  the  present  cost,  we  should  be  looking  at  all  of  the  other 
available  control  measures.   In  recent  years  there  has  been  an  attempt  by  the 
Bureau  of  Mines  and  others  to  arrive  at  cost  factors  for  other  control  tech- 
niques.  The  U.S.  Environmental  Protection  Agency  (EPA)  sponsored  a  2-month 
study  that  resulted  in  a  report  by  Kown  (9).   This  study  considered  the  mine 
as  a  whole  and  its  total  production  of  radon,  8.86  Ci/day.   Some  of  the  radon 
reductions  and  costs  given  by  Kown  (9)  are  shown  in  table  12.   Other  control 
measures  such  as  mine  pressurization,  the  use  of  highly  reactive  chemical 
oxidants,  and  specialized  mining  techniques  were  discussed,  but  costs  were 
not  calculated. 

TABLE  12.  -  Costs  for  radon  control  from  Kown  (9) 


Control  measure 

Radon  reduction, 
Ci/day 

Cost  per 
ton 

Activated  charcoal 
with  bulkheading. . . . 

1.01 
2.95 

3.01 

$1.45 
.34 

4.32 

Cost  figures  reported  by  the  Bureau  of  Mines  are  usually  for  single 
installations.   For  example,  the  materials  cost  of  an  8-  by  14-foot  bulkhead 
was  $186  to  $295  (]).      Radon  barrier  sealant  costs  per  square  foot  have  been 
$0.30  to  $1.19  ($0.46  to  $1.84  in  1980  dollars)  (_4).   The  most  expensive  coat- 
ing system  was  the  least  satisfactory  material  because  it  contained  chopped 
fiberglass.   Field  tests  of  sealants  showed  radon-stopping  power  of  up  to 
75  percent;  therefore,  they  can  reduce  the  amount  of  ventilation  needed  to 
control  the  radon-daughter  concentrations  to  a  given  level. 

Cost  figures  like  these  can  be  compared  with  the  cost  for  ventilation 
control.   To  accomplish  this,  the  cost  of  a  control  measure  must  be  expressed 
in  the  same  units  as  ventilation  costs — dollars  per  ton — and  the  effect  of  the 
new  control  measure  must  be  defined.   For  example,  cost  per  square  foot  is  the 
most  convenient  for  sealant  coatings,  and  this  can  be  related  to  a  cost  per 
ton  by  considering  the  surface  area  remaining  in  the  excavation  of  typical 
drifts.   In  a  6-  by  7-foot  opening,  about  8.2  square  feet  of  rock  is  exposed 
around  the  periphery  for  each  ton  of  rock  removed;  for  a  12-  by  14-foot 


17 


drift,  about  4.1  square  feet  of  surface  is  left  per  ton  of  rock  removed. 
Therefore,  sealant  coatings  cost  about  $2  or  $3  per  ton  (1980).   This  is  con- 
siderably less  than  the  estimated  $5.43  per  ton  for  present  radon-daughter 
control. 

CONCLUSIONS 

The  available  radiation  control  cost  information  has  been  analyzed  and 
yielded  the  equation:   Cost,  1967$/ton  =  3.134  (WLM)-0*3715.   Combining  limit- 
ing miner  exposure,  LME,  and  consumer  price  index,  CPI,  the  dollars  per  ton 
(DPT)  can  be  estimated  from  DPT  =  0.03624  CPI  (LME)-0*3715.  The  1967  cost  per 
ton  for  a  number  of  average  and  limiting  miner  working-level-month  exposures 
has  been  calculated  and  converted  to  a  1980  CPI  value.   At  a  LME  of  4  WLM,  the 
projected  cost  per  ton  for  radiation  control  is  $5.41.   If  the  LME  is  reduced 
to  0.7  WLM,  the  projected  cost  per  ton  is  $10.34.   These  values  are  only 
applicable  to  radiation  control  in  U.S.  sandstone-type  mines.   Considering 
the  projected  costs  per  ton,  any  reasonable  technology  should  be  used  in  the 
control  of  radon  and  radon-daughters. 


18 


REFERENCES 

1.  Arthur  D.  Little,  Inc.   An  Assessment  of  the  Ecomonic  Effects  of 

Radiation  Exposure  Standards  for  Uranium  Miners.   Rept.  to  the  Fed. 
Radiation  Council,  November  1970,  2d  ed. ,  250  pp. 

2.  .   Advanced  Techniques  for  Radon  Gas  Removal.   BuMines  Open  File 

Rept.  60-75,  May  1975,  209  pp.;  available  for  reference  at  BuMines 
facilities  in  Pittsburgh,  Pa. ,  Denver,  Colo. ,  Spokane,  Wash. ,  and  Twin 
Cities,  Minn.;  at  the  National  Library  for  Natural  Resources, 

U.S.  Dept.  of  the  Interior,  Washington,  D.C.;  and  at  the  Dept.  of 
Energy  facility  in  Morgantown,  W.  Va. ;  available  from  National  Tech- 
nical Information  Service,  Springfield,  Va. ,  PB  243  898;  BuMines 
contract  H0230022. 

3.  Baroch,  C.  T.   Uranium.   Ch.  in  BuMines  Minerals  Yearbook  1965.   V.  1. 

Metals  and  Minerals  (Except  Fuels),  pp.  973-991. 

4.  Bates,  R.C. ,  and  J.  C.  Franklin.   U.S.  Bureau  of  Mines  Radiation 

Control  Research.   Proc.  Conf.  on  Uranium  Min.  Technol. ,  Reno,  Nev. , 
Apr.  25-29,  1977,  32  pp. 

5.  Cross,  F.  T. ,  C.  H.  Bloomster,  P.  L.  Hendrickson,  and  I.  C.  Nelson. 

Evaluation  of  Methods  for  Setting  Occupational  Health  Standards  for 
Uranium  Mines.   Nat.  Inst,  for  Occupational  Safety  and  Health,  NIOSH 
Rept.  72-2,  1974,  237  pp.;  available  from  Nat.  Tech.  Inf.  Service, 
Springfield,  Va. ,  PB  237  744;  NIOSH  contract  HSM-99-72-135, 
Battelle-Pacif ic  Northwest  Laboratories. 

6.  Federal  Radiation  Council.   Guidance  for  the  Control  of  Radiation  Hazards 

in  Uranium  Mining.   FRC  Rept.  8,  rev.  September  1967,  60  pp. 

7.  Franklin,  J.  C,  C.  S.  Musulin,  and  D.  W.  Thebeau.   Research  on  Bulkheads 

for  Radon  Control  in  Mines.   Proc.  Update  on  Uranium  Min.  Technol., 
Reno,  Nev.,  Nov.  13-17,  1978,  11  pp. 

8.  Klemenic,  J.   Production  Capability.   Proc.  Update  on  Uranium  Min. 

Technol.,  Reno,  Nev.,  Nov.  13-17,  1978,  30  pp. 

9.  Kown,  B.  T. ,  V.  C.  Van  der  Mast,  and  K.  L.  Ludwig.   Technical  Assessment 

of  Radon  222,  Control  Technology  for  Underground  Uranium  Mines. 
Bechtel  National,  Inc.,  San  Francisco,  Calif.   Task  9,  1979,  61  pp. 

10.  Spencer,  N. ,  L.  Spittel,  T.  Towles,  and  G.  Lady.   Control  of  Radiation 

Exposure  in  Uranium  Mines:   A  Cost  and  Economic  Analysis.   Resource 
Management  Corp.,  Rept.  UR-42,  prepared  for  the  Federal  Radiation 
Council,  November  1968,  66  pp. 

11.  Thompkins,  R.  W.   Radiation  Control  in  North  American  Mines  and  Their 

Effects  on  Mining  Costs.   Proc.  7th  Internat.  Min.  Cong.,  Bucharest, 
Romania,  September  1972,  pp.  1-11. 

«  U.   S.   GOVERNMENT   PRINTING  OFFICE  :    1981    358-313/7175 


3964 


c\ 


y     V     '/     V 


«u    * 


«5^ 


^ 


.   »  o  -         ,  0 


V*1 

1  '  *  *  <3 


Gu    * 


o 


tP-^ 


3,0  V 


4>     .....    -V  0A        .....     -*b  AV    ..... 


• » •     A  <►     *^7vT  *     g^  V 


!•"•    ^ 


A3  "^ 


1*  0  •  "   «  *  _       * 


LIBRARY  OF  CONGRESS 


0  002  959  937  3 


Hi 


asm 


ml